Case Overview

Legal Principle at Issue

Whether a conviction under the Espionage Act of 1917 for circulating anti-war articles should be overturned on First Amendment grounds.


Affirmed (includes modified). Petitioning party did not receive a favorable disposition.


The defendant circulated a newspaper that criticized the United States’ involvement in World War I. He was charged under the Espionage Act of 1917 which granted the government wide latitude in punishing expression that could disrupt the United States’ war efforts. Affirming the defendant’s conviction, the Supreme Court stated, “a person may be convicted of a conspiracy to obstruct recruiting by words of persuasion.”

Importance of Case

This decision upheld the limits on war-time expression set by Schenck v. United States (1919).

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